Justia Wyoming Supreme Court Opinion Summaries

In 2023, Wyoming enacted two laws restricting abortion: the Life is a Human Right Act, which broadly banned abortion procedures with limited exceptions, and a separate statute prohibiting the prescription or use of drugs to induce abortions, also with exceptions. These laws imposed criminal and civil penalties on violators, excluding the pregnant person. After the laws took effect, several plaintiffs—including medical professionals, non-profit organizations, and an individual woman—challenged the statutes in District Court of Teton County, arguing they violated Article 1, Section 38 of the Wyoming Constitution, which guarantees each competent adult the right to make their own health care decisions.The district court granted summary judgment in favor of the plaintiffs, finding that the challenged laws unreasonably and unnecessarily infringed on the constitutional right to make health care decisions, and issued a permanent injunction preventing enforcement of the abortion restrictions. The State of Wyoming appealed directly to the Wyoming Supreme Court.The Wyoming Supreme Court, exercising de novo review, held that the decision to terminate or continue a pregnancy is a health care decision protected by Article 1, Section 38. The Court determined that this provision confers a fundamental right, and that statutes restricting it must satisfy strict scrutiny: the State must show such laws are narrowly tailored to achieve a compelling governmental interest and use the least restrictive means. The majority found that the State failed to present sufficient evidence that the abortion restrictions and their exceptions were the least restrictive means of protecting prenatal life. Accordingly, the Wyoming Supreme Court affirmed the district court’s ruling, holding the 2023 abortion laws unconstitutional under the Wyoming Constitution. View "State of Wyoming v. Johnson" on Justia Law

The case concerns a property owner who challenged the assessed valuation of his residential property by the county assessor. After receiving a tax assessment notice valuing his home at $732,661, the property owner met with the assessor to contest the figure, citing his home’s 2013 purchase price as more accurate. The assessor, after review, reduced the assessment twice—first lowering the quality rating of the home and then making a minor adjustment for siding type—ultimately setting the value at $674,465. The property owner appealed the assessment, objecting to the timing of evidence disclosure by the assessor and arguing that the assessed value should reflect actual sales in the neighborhood or a realtor’s market evaluation instead of the mass appraisal system used.The Laramie County Board of Equalization held a hearing on the appeal, admitting both parties’ evidence, including the assessor’s exhibits, which were received by the property owner three days later than the statutory deadline but still twenty-seven days before the hearing. The Board found the assessor’s methods and use of the state-mandated Computer Assisted Mass Appraisal (CAMA) system proper, and concluded that the property owner failed to provide credible evidence that the valuation was incorrect or unlawful. The Board affirmed the assessment. The property owner appealed to the State Board of Equalization, which remanded briefly for procedural reasons, after which the Board reaffirmed its decision. The State Board and then the District Court of Laramie County both affirmed.The Supreme Court of Wyoming reviewed the case and held that the County Board did not abuse its discretion in admitting the assessor’s evidence, given the minimal delay and lack of prejudice. It also held that the property owner did not meet his burden to rebut the presumption of correctness in the assessor’s valuation, which was supported by substantial evidence and in accordance with law. The Supreme Court affirmed the lower courts’ decisions. View "Johnston v. Ernst" on Justia Law

Timothy Hale and Sonja Ringen constructed a storage building on their commercially zoned property in Laramie without first obtaining a building permit. When the City of Laramie discovered the construction, it issued a stop work order and a cease-and-desist letter. Despite these notices, Hale and Ringen continued building and subsequently applied for a permit, which the City denied due to deficiencies in the application. After further unsuccessful permit attempts and ongoing disputes over the City’s requirements—including requests for disassembly of the structure—the City sought and obtained a permanent injunction from the District Court of Albany County, restricting use of the building until permitting was complete and compliance was achieved.The District Court of Albany County conducted a bench trial in May 2022 and granted the City’s request for a permanent injunction. The court outlined a process for inspections, identification of code violations, and corrective actions, but continued conflict between the parties hindered progress. Multiple rounds of correspondence, inspections, and motions ensued, with the City insisting on structural disassembly and Hale/Ringen providing documentation to support their position. Hale and Ringen eventually moved to vacate the injunction, arguing it was no longer equitable given their efforts and the City’s refusal to issue a permit. The district court denied their motion, citing only the parties’ lack of agreement, and provided no substantive analysis of the evidence.On appeal, the Supreme Court of Wyoming determined that the district court abused its discretion by failing to consider the evidence and arguments presented before denying the motion to vacate or modify the injunction. The Supreme Court held that a court must exercise discretion and decide motions on their merits, rather than requiring agreement between adversarial parties. Consequently, the Supreme Court reversed the district court’s order and remanded the case for full consideration of Hale/Ringen’s motion in light of all relevant facts and equities. View "Hale v. City of Laramie" on Justia Law

Russ and Debi Ropken hired a construction company to build a custom home based on an oral agreement. The contractor began work and sent invoices for services and materials, which the Ropkens paid until May 2022, after which they stopped making payments. In July 2022, the Ropkens removed the contractor from the site. The contractor then sent a demand letter for three unpaid invoices totaling $276,169, but the Ropkens refused to pay. The contractor sued to recover the unpaid amount.In the District Court of Park County, the Ropkens admitted owing at least $176,870.21. At the conclusion of a jury trial, the jury found there was a valid contract, the Ropkens had breached it, and awarded the contractor $258,587.70 in damages. The district court entered judgment for that amount and permitted the contractor to request prejudgment interest. The contractor timely filed for prejudgment interest, and the Ropkens objected. The district court found for the contractor, awarding $33,473.25 in prejudgment interest at a statutory rate, and calculated interest from the date of the demand letter. The Ropkens paid the judgment but appealed the prejudgment interest award.The Supreme Court of Wyoming reviewed whether the district court erred in awarding prejudgment interest and whether due process was violated by granting interest without an evidentiary hearing. The court held that a district court may award prejudgment interest even when it is not the trier of fact, as prejudgment interest is a matter of law and not fact. The court found the claim was liquidated and the Ropkens had notice. The court also held that the Ropkens received adequate notice and opportunity to be heard, satisfying due process. The Supreme Court of Wyoming affirmed the award of prejudgment interest. View "Ropken v. Yj Construction, Inc." on Justia Law

After marrying in July 2014, a husband and wife executed a postnuptial agreement two days after their wedding, intending to keep their respective properties separate during the marriage. Prior to marriage, they jointly purchased land, with the wife contributing a down payment and the remainder financed by a mortgage. After marriage, they constructed a home and acquired several vehicles, with the husband contributing substantially more toward improvements and purchases. The couple separated in late 2020, and the husband filed for divorce in early 2021. Disputes arose concerning the enforceability and interpretation of the postnuptial agreement, as well as the division and valuation of marital assets, especially the marital residence.The District Court of Albany County first granted summary judgment, finding the postnuptial agreement enforceable, rejecting the wife’s arguments of unconscionability and unilateral mistake due to lack of sufficient evidence. However, the court denied the husband’s subsequent request for summary judgment on the property distribution, interpreting the agreement to allow equitable division of assets acquired during the marriage. After a bench trial, the court divided the vehicles and the marital residence between the parties, awarded credits for their respective contributions, and ordered a current appraisal to determine the property’s value for final division. The court ultimately set the marital residence’s value at $925,000 and split the remaining equity equally after accounting for the parties’ contributions.On appeal, the Supreme Court of Wyoming affirmed the district court’s rulings. It held that the postnuptial agreement was enforceable, that its terms required the court to exercise discretion in distributing property acquired during the marriage, and that there was no abuse of discretion in the court’s valuation and division of the marital residence. The Supreme Court found the lower court’s findings and application of the law to be proper and supported by the record. View "Young v. Jones" on Justia Law

A minor child was injured in 2018 while playing on a piece of playground equipment called “Rocks and Ropes” at Meadowlark Elementary School in Cheyenne, Wyoming. The child’s parents, Scott and Heather Hunter, alleged that the equipment was defective and that the school failed in its supervision and medical care following the incident, as their daughter was diagnosed weeks later with a crushed vertebra. The Hunters sued Universal Precast Concrete, Miracle Recreation Equipment, Churchich Recreation Equipment, and Laramie County School District #1, alleging strict product liability, negligence, breach of warranty, and failure to warn.The case proceeded before the District Court of Laramie County. Due to extensive delays—including those caused by the COVID-19 pandemic—there were multiple changes to scheduling orders. The district court granted summary judgment in favor of the business defendants after excluding several of the Hunters’ expert witnesses under the Daubert standard, finding their testimony unreliable or irrelevant. The court denied summary judgment to the School District. After a mistrial was declared due to repeated improper conduct by the Hunters’ counsel during voir dire and opening statements, the district court dismissed the remaining claims against the School District with prejudice as a sanction for counsel’s actions and various procedural violations.The Supreme Court of the State of Wyoming affirmed the district court’s exclusion of the Hunters’ experts and the grant of summary judgment in favor of the business defendants, holding that the lower court properly performed its gatekeeping function and the Hunters failed to offer admissible evidence of a defect. However, the Supreme Court reversed the district court’s dismissal with prejudice, concluding that, while counsel’s conduct warranted sanctions, the extreme sanction of dismissal was not justified without prior warning or full consideration of lesser sanctions. The case was remanded for imposition of a lesser sanction. View "Hunter v. Universal Precast Concrete, Inc." on Justia Law

A married couple with two young children went through divorce proceedings after the mother filed for divorce. During the marriage, the mother was the primary caregiver, staying home with the children, while the father worked long hours as a mechanic and business owner. Both parties presented evidence at trial regarding their respective parenting abilities, disciplinary approaches, and their differing views on matters such as medical care and education. Testimony addressed concerns about each parent’s past drinking, interactions with the children, willingness to facilitate contact with the other parent, and incidents involving the children’s care.The District Court of Washakie County conducted a bench trial and, after evaluating the statutory best interest factors, awarded joint legal custody of the children to both parents. The court designated the mother as the primary residential caregiver and final decision-maker for major matters, granting the father regular parenting time, including certain weekends, evenings, holidays, and summer periods. The father appealed the custody determination, arguing that the court violated his constitutional rights by not granting equal parenting time and claiming the court abused its discretion in its allocation of parenting time.The Supreme Court of Wyoming reviewed the appeal. It held that, in custody disputes between two fit parents, the constitutional principles cited in cases like Troxel v. Granville do not require courts to allocate equal parenting time. Instead, the court reaffirmed that Wyoming law requires custody to be determined according to the best interests of the children, without any presumption in favor of equal or shared custody. The Supreme Court found that the district court had thoroughly considered the statutory factors, acted within its discretion, and did not violate the father’s fundamental rights. The Supreme Court of Wyoming affirmed the district court’s custody order. View "Smith v. Smith" on Justia Law

A company engaged in oil and gas production in Wyoming purchased electricity to operate equipment—primarily electronic submersible pumps and pumpjacks—that lifted fluids from underground, moved them to surface facilities for separation, and ultimately delivered the separated crude oil to custody transfer units (LACTs). The company sought a refund of sales tax paid on a portion of this electricity, arguing that the power was used for “transportation” and therefore exempt from sales tax under a statutory provision for those “engaged in the transportation business.” Utility studies commissioned by the company attempted to quantify what percentage of electricity was used for surface movement of fluids.A prior audit by the Wyoming Department of Revenue covering different years led to a similar refund dispute, but the Department conceded that the company was “engaged in the transportation business,” and the Wyoming State Board of Equalization ruled in the company’s favor. However, for the tax years at issue here, the Department denied the refund, asserting the company was not engaged in the transportation business as required by statute. The Board, after a contested hearing, again ruled for the company, finding it met the exemption, but the Department appealed, and the District Court certified the case to the Supreme Court of Wyoming.The Supreme Court of Wyoming held that collateral estoppel did not bar the Department’s appeal because the issue of whether the company was engaged in the transportation business was not actually litigated in the prior proceeding, but stipulated. On the merits, the Court reversed the Board’s decision. It found that the company’s activities—moving crude oil from the wellhead to the LACT and separating water—were part of the production process, not transportation. The company was not engaged in the transportation business as contemplated by the statute and the electricity was used for production, not actual transportation purposes. Thus, the company was not entitled to a sales tax exemption or refund. View "Department of Revenue v. PacifiCorp" on Justia Law

The plaintiffs, all residents, property owners, and taxpayers in Johnson County, Wyoming, brought a declaratory action against the county’s Board of Commissioners and the Wyoming Department of Audit (including its Director). Their complaint alleged that the Board mismanaged county finances and violated state fiscal statutes, and that the Department failed to enforce compliance. The plaintiffs claimed that these actions caused them tangible harm as taxpayers through increased taxes and fees. Their suit included ten counts, all seeking declarations of statutory or constitutional violations and requesting judicial oversight, including a forensic audit.The District Court of Johnson County reviewed the case after the Board and the Department moved to dismiss, arguing that the plaintiffs lacked standing to sue. The district court agreed, finding that the plaintiffs had not demonstrated a sufficient personal or particularized injury, and dismissed the complaint for lack of standing. The plaintiffs appealed to the Wyoming Supreme Court.The Supreme Court of Wyoming affirmed the district court’s dismissal. The court held that the plaintiffs failed to establish prudential standing under Wyoming’s Brimmer test, which requires a tangible personal stake in the outcome, not just a generalized grievance. The court also declined to recognize taxpayer standing, since the plaintiffs’ claims of increased tax burdens were speculative and unsupported by specific factual allegations. Even though the plaintiffs argued the case was of great public importance, the court held that public interest alone is insufficient to relax standing requirements without a concrete, particularized harm. As a result, the Supreme Court affirmed the dismissal of the action for lack of standing. View "Williams v. Board of County Commissioners of Johnson County" on Justia Law

Law enforcement officers in Albany County, Wyoming, arrested an individual who had an outstanding warrant and was found in possession of controlled substances. During the arrest, officers located his truck, had a K9 unit alert to it, and towed it to an evidence bay. After obtaining a warrant, they searched the truck and seized substances later determined not to be illegal drugs. The truck was then released by law enforcement to a towing company, where it was placed in storage pending payment of fees. The owner was not notified of this arrangement until several months later. By the time he learned of the truck’s location, storage fees had accumulated to an amount he could not pay, and the truck was eventually sold at auction. The owner asserted he never received notice that the truck could be sold to cover the fees.The District Court of Albany County heard the owner’s pro se motion for return of the truck or, alternatively, for compensation equal to its value. The State responded that it no longer had possession of the vehicle, as it had been released to the towing company and not seized for forfeiture. After a hearing, the district court denied the motion, concluding it lacked authority to order return of property it no longer possessed or to award money damages under Wyoming Rule of Criminal Procedure 41(g).The Supreme Court of Wyoming reviewed the case and held that a court has no jurisdiction under Rule 41(g) to order the return of property or award damages when the government no longer possesses the property. The court reaffirmed that sovereign immunity bars monetary relief under this rule and that any claim for damages must proceed as a separate civil action under the Wyoming Governmental Claims Act. The Supreme Court of Wyoming affirmed the district court’s denial of the motion. View "Bressette v. State" on Justia Law